Effective Date: May 15, 2018
Welcome and thank you for your interest in Elevay LLC (“Elevay”, “we” or “us”), our website at http://www.elevay.com and subdomains (“Sites”), related services provided by us, and all other communications with individuals through written or oral means, such as email or phone, (collectively, together with our site, our “Service”)
We collect different types of personal information in the delivery of our Services. The legal basis for the processing of personal data is primarily that this information is necessary to provide a Service and is in Elevay’s legitimate interest. Services include the performance of tasks as requested by you, such as a consultation, or, in the case of clients, the performance of contracted duties.
The information collected by Elevay is used in a variety of ways to provide the Service and operate our business, including the following:
Elevay is concerned with protecting your privacy and data. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal data in our possession. But we cannot ensure or warrant the security of any information you transmit to Elevay or guarantee that your information may not be accessed, disclosed, altered or destroyed by any breach of the industry standard physical, technical or managerial safeguards we have implemented. No method of transmission over the internet or method of electronic storage is 100% secure, therefore we cannot guarantee its absolute security, and so you do so at your own risk. If you believe your Personal Data has been compromised, please contact firstname.lastname@example.org. If we learn of a security breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
Elevay self-certifies compliance with the EU GDPR framework as set forth by the European Union regarding the collection, use and retention of personal data from European Union member countries. Elevay has certified that adheres to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.
Under the GDPR, citizens of the EU are afforded the following rights:
In addition, the third-party services we use have certified their participation and compliance with the Privacy Shield framework. This allows the transfer of personal data outside of the European Union, provided an adequate level of protection exists for the personal data in the country or organization the data is being transferred:
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in Elevay Services so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: (a) advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements; (b) attribution partners, which measure the effectiveness of certain advertisements; and (c) business partners, which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third parties collect enables us to learn what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.
Elevay and third party vendors, including Google, use first-party cookies (Google Analytics cookie) and third party cookies (DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to our website. More specifically, our website has implemented and uses display advertising and we utilize Google Analytics to implement a specific feature called remarketing. Remarketing is a feature of Google’s AdWords that allows us to optimize the delivery of ad content specifically targeted to a visitor’s interests based upon previous visits to our site. If you’d like more information about remarketing lists in Google Analytics please visit the following site – https://support.google.com/analytics/answer/2611268″
If you would like to opt-out of Google Analytics for display advertising you may do so by using the Ads Preferences Manager – https://adssettings.google.com/
You may also use the Google Analytics opt-out browser add on that you can download at https://tools.google.com/dlpage/gaoptout/.
In the event that personal information is compromised as a breach of security, Elevay will promptly notify our customers in compliance with applicable law.
For current Elevay users and clients, you can request to review, correct, update or delete information that Elevay keeps on file by submitting a request to email@example.com. Email submissions will be reviewed and replied to within 72 hours.
Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your requests.
In the case of email communications, you will be able to withdraw your consent at any time via an unsubscribe link included at the bottom of emails we send.
Should you have any complaints about your privacy and our collection or use of your personal information, please contact us at firstname.lastname@example.org to resolve the concerns.
We do not knowingly collect or solicit personal information from anyone under the age of 18 from our sites. As a requirement of a Service contract, it may be necessary to collect information on a client’s child to fulfill the contractual Service, but in this case, parental consent will be obtained. The Service is not intended to be used by minors. If you are a parent or guardian and discover your child under 18 years of age has submitted information to us, please alert us at email@example.com and request that we delete that child’s Personal Data from our systems.